The Annual Report’s central section is a series of case studies. This format is a godsend to the annual report compiler who knows he can’t put out a 15 page report. <\/p>\n
Most of them have been anonymised. However, a few have left the relevant party’s names in. Whether this is because the story is better that way, or as an oblique form of commentary is impossible to tell.<\/p>\n
I received a number of complaints against Stein Travel about the marketing of a Stein
\nTravel\/MBNA credit card. It transpired that Stein Travel had provided all the relevant
\ncontact data of its customers to MBNA.
\nWhen my staff enquired about this, Stein Travel
\nwere of the opinion that they were compliant with
\nthe Data Protection Acts in conducting their
\ncampaign. On their booking form under the heading
\nof Data Protection it is stated that \u2018The information
\nthat we use is for fulfilling our contract as a tour
\noperator\/holiday provider. We may from time to
\ntime, make your information available to companies
\nwithin our group.\u2019
\nAs MBNA was not a company within the group and
\nas marketing a credit card is not the same as
\nmarketing a holiday, it was held that consent from
\ncustomers should have been obtained prior to the
\nmarketing of the Stein Travel\/MBNA credit card.
\nWhen this was brought to Stein Travel\u2019s attention,
\nthey initiated an immediate cessation to the
\ncampaign and undertook to review their entire
\nprocedures relating to storing and processing data
\nand their marketing practices where promotional
\npartners are involved.
\nThe case illustrates the importance of being
\nclear about marketing practices – a credit card,
\neven a co-branded one, is not considered by me
\nto be a product or service similar to the
\nprincipal business. In these circumstances, the
\nonus is on the travel agent to ensure that
\nconsent is given for this type of direct
\nmarketing.<\/p><\/blockquote>\nAs I say, there are a number of case studies. They’re all about a page long, and if you have the inclination I’d recommend a browse through them to see the kinds of things people can get up to.<\/p>\n","protected":false},"excerpt":{"rendered":"The Annual Report’s central section is a series of case studies. This format is a godsend to the annual report compiler who knows he can’t put out a 15 page report. Most of them have been anonymised. However, a few have left the relevant party’s names in. Whether this is because the story is better that way, or as an oblique form of commentary is impossible to tell. I received a number of complaints against Stein Travel about the marketing of a Stein Travel\/MBNA credit card. It transpired that Stein Travel had provided all the relevant contact data of its customers to MBNA. When my staff enquired about this, Stein Travel were of the opinion that they were compliant with the Data Protection Acts in conducting their campaign. On their booking form under the heading of Data Protection it is stated that \u2018The information that we use is for fulfilling our contract as a tour operator\/holiday provider. We may from time to time, make your information available to companies within our group.\u2019 As MBNA was not a company within the group and as marketing a credit card is not the same as marketing a holiday, it was held that consent from customers should have been obtained prior to the marketing of the Stein Travel\/MBNA credit card. When this was brought to Stein Travel\u2019s attention, they initiated an immediate cessation to the campaign and undertook to review their entire procedures relating to storing and processing data and their marketing practices where promotional partners are involved. The case illustrates the importance of being clear about marketing practices – a credit card, even a co-branded one, is not considered by me to be a product or service similar to the principal business. In these circumstances, the onus is on the travel agent to ensure that consent is given for this type of direct marketing. As I say, there are a number of case studies. They’re all about a page long, and if you have the inclination I’d recommend a browse through them to see the kinds of things people can get up to.","protected":false},"author":1,"featured_media":0,"comment_status":"open","ping_status":"open","sticky":false,"template":"","format":"standard","meta":{"footnotes":""},"categories":[5,1],"tags":[92,91,88,45,90,19,93],"class_list":["post-221","post","type-post","status-publish","format-standard","hentry","category-digital-rights","category-general","tag-annual-report","tag-data-protection","tag-data-protection-commissioner","tag-digital-rights-ireland","tag-dpa","tag-ireland","tag-state"],"_links":{"self":[{"href":"https:\/\/www.tuppenceworth.ie\/blog\/wp-json\/wp\/v2\/posts\/221","targetHints":{"allow":["GET"]}}],"collection":[{"href":"https:\/\/www.tuppenceworth.ie\/blog\/wp-json\/wp\/v2\/posts"}],"about":[{"href":"https:\/\/www.tuppenceworth.ie\/blog\/wp-json\/wp\/v2\/types\/post"}],"author":[{"embeddable":true,"href":"https:\/\/www.tuppenceworth.ie\/blog\/wp-json\/wp\/v2\/users\/1"}],"replies":[{"embeddable":true,"href":"https:\/\/www.tuppenceworth.ie\/blog\/wp-json\/wp\/v2\/comments?post=221"}],"version-history":[{"count":0,"href":"https:\/\/www.tuppenceworth.ie\/blog\/wp-json\/wp\/v2\/posts\/221\/revisions"}],"wp:attachment":[{"href":"https:\/\/www.tuppenceworth.ie\/blog\/wp-json\/wp\/v2\/media?parent=221"}],"wp:term":[{"taxonomy":"category","embeddable":true,"href":"https:\/\/www.tuppenceworth.ie\/blog\/wp-json\/wp\/v2\/categories?post=221"},{"taxonomy":"post_tag","embeddable":true,"href":"https:\/\/www.tuppenceworth.ie\/blog\/wp-json\/wp\/v2\/tags?post=221"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}